← Product Code [MBI](/productcode/MBI) · K133579

# MULTIFILAMENT STAINLESS STEEL SUTURES WITH CRIMPS (K133579)

_Pontis Orthopaedics, LLC · MBI · Jun 26, 2014 · Orthopedic · SESE_

**Canonical URL:** https://fda-staging.innolitics.com/device/K133579

## Device Facts

- **Applicant:** Pontis Orthopaedics, LLC
- **Product Code:** [MBI](/productcode/MBI.md)
- **Decision Date:** Jun 26, 2014
- **Decision:** SESE
- **Submission Type:** Traditional
- **Regulation:** 21 CFR 888.3040
- **Device Class:** Class 2
- **Review Panel:** Orthopedic
- **Attributes:** Therapeutic

## Indications for Use

Multifilament stainless steel sutures with crimps are intended for use in soft tissue to bone and bone to bone approximation and fixation during orthopedic procedures in the elbow, foot, ankle, knee, shoulder, and wrist for indications such as: Elbow - biceps tendon attachment; Foot and Ankle - achilles tendon attachment; Knee - patella tendon attachment to bone; Shoulder -biceps tendon tenodesis; Wrist - scapho-lunate approximation.

## Device Story

Multifilament stainless steel sutures with crimps facilitate soft tissue-to-bone and bone-to-bone fixation during orthopedic surgery. The system comprises stainless steel sutures (USP sizes 4-0 to #3) in 1x19, 7x7, or 7x19 filament constructions, paired with stainless steel needles and metallic crimps. Used by orthopedic surgeons in clinical settings, the device provides mechanical approximation of tendons or bone segments. The surgeon secures the suture using the crimp mechanism to maintain tension. The device is provided sterile for single use. Benefits include stable fixation of tendons and bone during the healing process.

## Clinical Evidence

Bench testing only. Mechanical verification and validation included knot failure force, crimp failure force, pull-out strength, attachment strength, and static/ultimate load testing following cyclic loading. Results demonstrated mechanical properties substantially equivalent to predicate devices for tendon-to-bone and bone-to-bone approximation.

## Technological Characteristics

Materials: Stainless steel sutures and crimps. Construction: 1x19, 7x7, or 7x19 filament configurations. Sizes: USP 4-0 to #3. Sterilization: Ethylene oxide. Single-use, sterile implantable device.

## Regulatory Identification

A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.

## Predicate Devices

- Mitek G11 Quick Anchor Plus ([K041115](/device/K041115.md))
- Arthrex Swivelock ([K101823](/device/K101823.md))
- Smith and Nephew Endobutton ([K081098](/device/K081098.md))
- PONTIS Orthopaedics ferroFIBRETM ([K081060](/device/K081060.md))
- Pioneer Surgical Technologies SilCoat Sternal Cable ([K993286](/device/K993286.md))

## Submission Summary (Full Text)

> This content was OCRed from public FDA records by [Innolitics](https://innolitics.com). If you use, quote, summarize, crawl, or train on this content, cite Innolitics at https://innolitics.com.
>
> Innolitics is a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices, including [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/).

{0}------------------------------------------------

# JUN 2 6 2014

# ATTACHMENT 2

J

Image /page/0/Picture/3 description: The image shows the word "PONTIS" in a stylized font. There is a curved line above the word, and the letters are outlined in black. To the right of the word is the trademark symbol.

ORTHOPAEDICS

## 510(k) Summary

| Owner's Name                                                          | Leonard Gordon                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
|-----------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitter Address                                                     | 2299 Post Street Suite 107<br>San Francisco, CA 94115                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |
| Phone Number                                                          | (415) 567-8935                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| Fax Number                                                            | (415) 567-8934                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| 510(k) Owner                                                          | PONTIS Orthopaedics, LLC                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |
| Contact Person                                                        | Leonard Gordon                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| Date Prepared                                                         | April 22, 2014                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| Trade Name                                                            | Multifilament Stainless Steel Suture with Crimp                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| Common name                                                           | Stainless Steel Suture                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |
| Classification Name                                                   | Smooth or Threaded Metallic Bone Fixation Fastener                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
| Section                                                               | § CFR 888.3040                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| Product Code                                                          | Primary - MBI                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |
| Predicate Device(s)                                                   | Mitek G11 Quick Anchor Plus - K041115<br>Arthrex Swivelock - K101823<br>Smith and Nephew Endobutton - K081098<br>PONTIS Orthopaedics ferroFIBRETM - K081060<br>Pioneer Surgical Technologies SilCoat Sternal Cable - K993286                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |
| Device Description                                                    | Multifilament stainless steel sutures with crimps are intended for use in<br>soft tissue to bone and bone to bone approximation and fixation during<br>orthopedic procedures in the elbow, foot, ankle, knee, shoulder, and<br>wrist for indications such as: Elbow - biceps tendon attachment; Foot<br>and Ankle - achilles tendon attachment; Knee - patella tendon<br>attachment to bone; Shoulder -biceps tendon tenodesis; Wrist -<br>scapho-lunate approximation.<br><br>Multifilament Stainless Steel Sutures with Crimps are available in a<br>range of USP sizes (4-0 to #3) and lengths, attached to stainless steel<br>needles of various types and sizes.<br><br>Multifilament SS Sutures are manufactured in IX19, 7X7 or 7X19<br>filament constructions. The sutures are identified by black and white<br>tips which are used as a guide at the tip, and are removed prior to the<br>end of the procedure. The sutures and tips were cleared for use under<br>the PONTIS 510(k), K101126. |
| The washer is available in the following sizes:                       |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| 000-0739_1-01 Washer, Plate - 0.012", .045"                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| 000-0739_1-00 Washer, Plate - 0.012", .062"                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| 000-0764 Washer, Plate, 2-Hole - 0.012"                               |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| The suture guide and the cannulated K-wire are available in one size. |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |
| Reason for 510(k)<br>Indications for Use                              | New Device<br>Multifilament stainless steel sutures with crimps are intended for use in<br>soft tissue to bone and bone to bone approximation and fixation during<br>orthopedic procedures in the elbow, foot, ankle, knee, shoulder, and<br>wrist for indications such as: Elbow - biceps tendon attachment; Foot<br>and Ankle - achilles tendon attachment; Knee - patella tendon<br>attachment to bone; Shoulder -biceps tendon tenodesis; Wrist -<br>scapho-lunate approximation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |
| Technological<br>Characteristics                                      | The Multifilament stainless steel suture is the same suture as was<br>cleared under K081060. Each suture size and number of suture strands<br>will require a different crimp size.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |
|                                                                       | All biocompatibility testing performed, which was conducted under the<br>predicate submission K081060 remain applicable for this submission-<br>as the materials are the same. This indicates that the components are<br>safe for their intended use.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |
|                                                                       | The PONTIS Multifilament Stainless Steel Suture with Crimps is a<br>single use, sterile implantable device, sterilized by ethylene oxide. The<br>predicate devices are single use, sterile implantable device, sterilized<br>by gamma irradiation and ethylene oxide.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |
| Substantial<br>Equivalence                                            | The Multifilament Stainless Steel Suture with Crimps is substantially<br>equivalent in design, manufacturing materials, intended use, principles<br>of operation, and technical characteristics to the predicates. The risk<br>analysis performed, raised no new issues of safety or effectiveness.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |
| Nonclinical Tests<br>Performed                                        | The verification and validation testing of the Multifilament Stainless<br>Steel Suture with Crimps included knot failure force compared to<br>crimp failure force, pull out strength, attachment strength, static testing<br>and ultimate load following cyclic loading. Bench testing<br>demonstrated that the mechanical properties are substantially<br>equivalent for tendon to bone and bone to bone approximation.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |
| Conclusions Drawn                                                     | Bases on the indications for use, technological characteristics and<br>performance test results, the Multifilament Stainless Steel Suture with<br>Crimps is substantially equivalent to the predicate.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |

PONTiS Orthopaedics

:

. '

{1}------------------------------------------------

:

{2}------------------------------------------------

Image /page/2/Picture/0 description: The image shows the text "DEPARTMENT OF HEALTH & HUMAN SERVICES" in bold, uppercase letters. The text is horizontally oriented and appears to be a header or title. The words are evenly spaced and the font is consistent throughout the text.

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

June 26, 2014

PONTiS Orthopaedics LLC Leonard Gordon, M.D. President 2229 Post Street, Suite 103 San Francisco, California 94115

Re: K133579

Trade/Device Name: Multifilament Stainless Steel Sutures with Crimps Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: MBI Dated: May 19, 2014 Received: May 20, 2014

Dear Dr. Gordon:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

{3}------------------------------------------------

forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resources[orYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

# Lori A. Wiggins

- for
Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{4}------------------------------------------------

#### ATTACHMENT 1

#### Statement of Indications for Use

510(k) Number: K133579

Manufacturer: PONTiS Orthopaedics, LLC

Device Name: Multifilament Stainless Steel Sutures with Crimps

Indications for Use:

Multifilament stainless steel sutures with crimps are intended for use in soft tissue to bone and bone to bone approximation and fixation during orthopedic procedures in the elbow, foot, ankle, knee, shoulder, and wrist for indications such as: Elbow - biceps tendon attachment; Foot and Ankle - achilles tendon attachment; Knee - patella tendon attachment to bone; Shoulder -biceps tendon tenodesis; Wrist - scapho-lunate approximation.

Prescription Use XX (21 CFR Part 801 Subpart D)

AND/OR

Over the Counter Use (21 CFR Part 801 Subpart C)

### (PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)

### Concurrence of CDRH, Office of Device Exemption (ODE)

Casey L. Hanley, Ph.D.
Division of Orthopedic Devices

Page 1/1

PONTiS Orthopaedics

6/23/14

---

**Source:** [https://fda-staging.innolitics.com/device/K133579](https://fda-staging.innolitics.com/device/K133579)

**Published by [Innolitics](https://innolitics.com)** — a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices. If you're preparing [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/), [get in touch](https://innolitics.com/contact).

**Cite:** Innolitics at https://innolitics.com
